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Modeling of the river sys tem should use full Gunnison Tunnel and M&D Canal <br />capacities during the irrigation season ; and Ridgway should be shown to simulate the <br />maximum exchange of the M&I pool for the entire study period, and not be limited to <br />historical demands. Redlands diversi ons should be shown at the maximum divertible <br />under its water rights. <br /> <br />The b aseline should reflect the terms of water decrees, particularly Case CA 5782, that <br />indicate that Crystal releases be made “insofar as available, be in such quantity as will <br />satisfy at all times prior decrees from said Gunnison River below the Crystal Dam when <br />commingled with the natural accretions in the channel of said river.” In the Districts’ <br />view, the term insofar as available means that Reclamation is obligated to make releas es <br />from the Unit to satisfy downstream seniors, unless the water surface elevation at Blue <br />Mesa is below the minimum necessary to operate the Blue Mesa powerplant. Recent <br />operations do not represent an appropriate baseline because operations have not met these <br />obligations. <br /> <br />Alternatives should include something similar to the 1995 fish ladder agreement and a <br />similar agreement should be extended to the entire year. <br /> <br />Alternatives should not make up endangered fish flow shortages downstream in the <br />Colorado Ri ver ; the Aspinall Unit has enough to do as the reasonable and prudent <br />alternative for Gunnison Basin Projects without having to make up for failures by Denver <br />and the Colorado Big Thompson Project to mitigate their transmountain depletions. <br /> <br />A Gunnison PBO process should be initiated and run concurrently with the Aspinall EIS. <br /> <br />Setting aside a portion of Aspinall Unit water for future marketing is premature and not <br />supported by the NOI of the EIS. <br /> <br /> Upper Gunnison Water Conservancy District: <br /> Reclamation s hould clarify <br />whether the proposed action should avoid jeopardy or strive for recovery of endangered <br />fish. Improved accuracy in measuring water storage in Blue Mesa is needed. The role of <br />the Unit in meeting compact deliveries needs to be considered in a lternatives. A <br />Gunnison Basin PBO should be integrated into or coordinated with the EIS process and <br />alternatives should be designed to serve as a reasonable and prudent alternative for all <br />Gunnison basin depletions. Existing commitments should be recogni zed and maintained <br />in the process and in the baseline; for example the Taylor Park Exchange Agreement, the <br />60,000 acre - foot subordination, protection from downstream calls, and reservoir targets <br />related to ice - flooding. <br /> <br /> Dolores Water Conservancy District : <br />Under the 1980 Dolores Project <br />biological opinion, the reasonable and prudent alternative (under ESA) consists of <br />releases from CRSP reservoirs, historically the Aspinall Unit. The District seeks <br />assurance that the EIS will continue to include releases from the Aspinall Unit to serve as <br />ESA coverage for the Dolores Project. The EIS should not preclude Colorado from <br />developing its compact water and, specifically, should not preclude th e ability of Dolores <br /> 19 <br />